AccorHotels, the world's leading hotel operator and market leader in Europe, is present in 94 countries with more than 3,790 hotels and 495,000 rooms under the hotel brands: Sofitel, Pullman, MGallery, Grand Mercure, Novotel, Suite Novotel, Mercure, Adagio, ibis, ibis Styles, ibis Budget, Hotel Formule 1, hotelF1 and Thalassa sea & spa. With more than 180,000 hoteliers in Accor brand hotels worldwide, the Group offers its clients and partners nearly 45 years of know-how and expertise.

AccorHotels is concerned by the .HOTELS registration policy as described in the “New gTLD Application” submitted by Booking.com on 12 January 2016. Although AccorHotels notes that in this new version, Booking.com has renounced “to implement[ing] a single registrant TLD” (Cf. previous version dated 13 June 2012), we are however concerned that Booking.com’s new registration policy now specifies that “only Booking.com and Eligible Trusted Third Parties will be entitled to register domain names” (Cf. Section 18A and 18C). Indeed, “Eligible Trusted Third Parties” (i) is not defined by Booking.com; (ii) obviously covers a restricted group of persons; (iii) entails that Booking.com will not give an open access to .HOTELS but rather decide, on discretionary criteria, who should be considered an Eligible Trusted Third Party. This not only creates an uncertainty as to the eligibility of future registrants, but more generally is against the essence of a Generic TLD such as .HOTELS which access must be guaranteed to all of the hotel market and community.

AccorHotels further notes that, more than four years after filing its application, Booking.com still points in its registration policy that:

“[…] we have not yet defined in details:

- the types of domain names that will be registered;

- who will be entitled to select which domain names will be registered;

- who will be entitled to register such domain names;

- who will be entitled to use such domain names, and;

- which types of use will be allowed or recommended.”

The above omissions and/or contradictions on crucial aspects of the considered management of the .HOTELS TLD not only breach ICANN‘s standard policies but also raise critical competition concerns: